This section works to prevent the loss of containment of process plant and equipment. A separate specialist team within the Energy Division conducts fire and explosion control and mitigation.
We are concerned with process safety issues particularly in terms of integrity and the prevention of loss of containment of hydrocarbon inventories.
We provide a centre of specialist expertise, relevant to the offshore industry, in process safety, process integrity and chemical engineering;
Our work directly supports the Departmental Strategic Objectives target for reduction in offshore hydrocarbon releases through:
Inspection prioritisation takes account of current key programmes and other OSD projects. We also prioritise topics based on statistical evidence and experience from inspections and investigations.
We develop and use internal guidance to ensure consistency and transparency in our dealings with dutyholders.
The main guidance we use as a basis for inspection and assessment is available on the internet or otherwise publicly available.
We have special responsibility for investigation of hydrocarbon release incidents and cascade the lessons learned both internally and externally.
We employ suitably competent and experienced staff (chartered engineer or equivalent and mostly chemical engineers although mechanical engineering is also relevant). In line with HSE’s Investor in People status, we provide relevant training as required by business need.
We make use of other suitably competent staff in HSE and HSL as required for inspection and assessment work. A number of onshore HSE inspectors from the process safety pool are conducting joint visits for familiarisation.
OSD’s involvement in assessment as a whole will reduce as a natural outcome of the new safety case regulations.
We conduct our assessments in accordance with the Safety Case Handling and Assessment Manual (SCHAM), Assessment Principles for Offshore Safety Cases (APOSC), and other relevant codes, standards and guidance.
We aim to complete assessment before acceptance of a safety case. Putting important issues off as Post Acceptance Inspection Topics (PAITs) is to be avoided. A dutyholder can reasonably expect that such issues will not be raised following acceptance of the safety case.
We use safety cases as an important way of understanding major accident hazards and hence prioritising inspection.
We contribute our expertise as appropriate in the execution of Key Programmes.
Inspections of dutyholder’s management systems, policies, evidence of good design, implementation of standards, codes and the adoption of good practice at land-based offices are as important as offshore inspection.
We use intelligence from safety case assessment, investigations, inspections and the hydrocarbon release database as an input to prioritising inspections.
We have special responsibility for investigation of hydrocarbon release incidents, including liaison with Statistics Section, ensuring sufficient investigation of incidents, that the causes are understood, and cascading the lessons learned both internally and externally.
We consider RIDDOR reports and proactively contact the relevant inspection management team (IMT) as required to initiate investigation.
e encourage IMTs to contact us automatically when an incident has occurred.
We identify knowledge gaps, which require research to assist the industry to prevent major accident hazards, and encourage the industry to take forward such research, either individually or jointly e.g. establishing best practice on entry into confined spaces on floating production and storage operations (FPSOs).
We undertake work in support of our own internal guidance.
There are currently no identified specific process integrity related requirements for research work.
We use HSE’s process safety pool network to talk regularly to those in other parts of HSE about how they conduct their work to identify any gaps in our knowledge.
We provide input to joint industry guidance relevant to the topic, e.g. HSG253 ‘The safe isolation of plant and equipment’, and subject to HSE’s policy on participation in the development of standards and guidance.
We promote inherent safety in design by making the industry aware of new inherently safer developments in design.
Feedback indicates a number of recurring problems in design, modification, operation and maintenance which we intend to address by further inspection.
Riser valves. Inspections show that even the most important emergency shutdown valves (as identified in the Piper Alpha Disaster Inquiry) namely the pipeline riser valves are not tested rigorously, and the proof test intervals are not always risk-based. The current inspection project conducted in conjunction with pipelines, and control and instrumentation inspectors is examining riser valves, their control systems, reliability and performance; and the interface with manufacturers. Standards for emergency shutdown valves for segregation of process inventories are even less well-defined. We will jointly prepare guidance on good practice.
Inherent safety. We will keep in touch with developments in the main design houses, so that inherent safety can be implemented early in a project.
International design issues. Recent experience has shown that process engineering designs originating outside the UK do not reflect the required UK regulatory standards of health and safety, nor the UK industry guidance, nor good UK industry practice. There is also over-reliance on American codes of practice which as a whole satisfy UK regulatory requirements, but there are exceptions which we need to identify explicitly.
Hazard and risk analysis for plant protection. In conjunction with control and instrumentation, and fire and explosion inspectors, we will prepare guidance on the application of formal safety assessment methods in the design of plant protection systems. This will include HAZID/risk assessment in general and the use of fault trees and cause consequence diagrams. The guidance should identify the different methods, their strengths and weaknesses and provide good practice guides for them. We will also propose risk targets to be achieved for individual and societal risk on offshore installations.
Ageing installations. We will contribute to Guidance on how we will tackle problems posed by ageing installations being planned by OSD3 as a whole.
SILs and their application. There are an increasing number of activities involving tie-back of new production wells to existing facilities. The reception facilities cannot always easily accommodate the new pressure relief requirements without an extensive revamp of the HP Flare disposal system. Increasingly reliance is being placed upon instrumented protective systems for over-pressure protection. Oil and Gas UK has produced Safety Integrity Level (SIL) guidance for the specification of trip systems but not all dutyholders apply it. Risk graphs, and Layers of protection analysis (LOPA) is being widely used offshore but there are arguments even amongst the experts on the degree of independence needed. We need to prepare guidance jointly with Control and Instrumentation inspectors on SIL assessment and estimation of demand rates and make it clear that the whole system needs to be considered, not just individual trips.
Benchmarking. We will benchmark dutyholders against good practice identified from the KP1 key programme, which reduced potential causes of loss of containment of hydrocarbons.
Process Isolation. Revision of OIAC guidance on safe isolation of plant and equipment has enhanced standards of process isolation integrity arising from reclassification of hardware requirements as a function of process fluid composition, provision of testing arrangements, and human factor aspects of implementation. We will inspect to examine the extent to which this guidance is being implemented.
Operational risk assessment. We will input to guidance being produced by fire & explosion inspectors on operational risk assessment. This needs to include partial reinstatement; dealing with design legacy (and aspects of design which are not written down) e.g. relying on a risk assessment if isolation is not adequate to HSE guidance.
How to tackle human failure to be aware of hazards/risks. This is the cause of many incidents. A toolkit is required of questions that inspectors could ask where the nature of the answer would suggest whether the respondent/dutyholder/system was thinking widely enough or was complacent. In conjunction with human factors inspectors we need to increase the knowledge base and awareness, perhaps by developing a sample toolkit to focus information better at teashack talks.
Performance indicators. Performance indicators need to be developed beyond the HSE guidance (HSG 254) for offshore application on an installation by installation basis (not generic for a dutyholder). Some possible generic indicators are hydrocarbon releases; anomalies after inspection; outages and shutdowns. This may not be sufficient. Produce a semi permanent circular (SPC) on performance indicators and relate to HSG 254.
Operator competency. We have identified Industry standards for demonstration of the competence of production operators, and control room operators. We will lead audits into the dutyholders arrangements to ensure competence in these areas.
Review and update the Loss of Containment Manual. This needs to be reviewed, checking current status and bringing up-to-date as necessary.
Review and update the process safety management SPC. This may need to be relaunched under another name. Inspection guidance could be hung off it, e.g. a ‘process integrity pack’ (paper or virtual) bringing the team’s guidance all together under one heading. This might make use of EDRM.
General expectations of key items of equipment from a process safety point of view. This would be particularly useful to new members of the team and inspectors from the process safety pool. Input/revision of the gas production training manual and other related documentation will provide a foundation. It would also help consistency. It could usefully include: Installations; Generalised P&ID or flow diagram; Key items of equipment; Key problem areas; Scenarios; Measures in place; Gaps; Enforcement issues; Inspection issues; Available guidance.
Benchmarking. We will benchmark dutyholders against the KP3 key programme, which investigated the suitability of the management of maintenance and identified good practice.
Audit of barriers. One of the outcomes of KP3 is a project on the audit of barriers. This is concerned with inspecting and stimulating dutyholders’ ability to audit themselves and to make improvements to both the barriers themselves and their audit process itself. We are currently taking part in a pilot exercise.
Guidance on how to inspect audits and what HSE expects. This is in the development stage as an outcome of KP3.
We will keep in touch with what is going on/developments in the main design houses, so that this may be influenced early.